ML19326C143
| ML19326C143 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/15/1971 |
| From: | Murphy W ARKANSAS POWER & LIGHT CO. |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8004210644 | |
| Download: ML19326C143 (38) | |
Text
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Regulatory .Fue -Cy.
THis DOCUMENT CONTAINS P00R QUAUTY PAGES O #
Before the UNITED STATES ATOMIC ENERGY COMMISSION Docket No. 50-313 In the Matter of
' Arkansas Power & Light Company STATEMENT UNDER SECTION E OF APPENDIX D TO 10 CFR 50 This statement it submitted by Arkansas Power & Light Company (Applicant) pursuant to Paragraph III of Section E of Revised Appendix D to Title 10, Code of Federal Regulations, Part 50 (effective September 9, 1971), as amended. A con-struction permit was issued to Applicant for the construction of Arkansas Nuclear One--Unit 1 (Unit 1) on December 6, 1968.
No operating license has been issued for Unit 1, and therefore this proceeding is subject to NEPA review under Section C of said Appendix D. Under date of June 8, 1971, Applicant transmitted to the Commission its. Environmental Report for Unit 1 prepared in accordance with the regulations of the Commission in effect at that time. This Report has been noticed and circulated for comment, and to that extent the
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NEPA environmental review asas already begun. Applicant is in the procnss of preparing a supplement to its Environmental Report on Uni 1 pursuant to the requirements of Section C of presently effective Appendix D and anticipates that the r NEPA environmental review of Unit 1 will proceed as quickly
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/ as the Commission may find practicable.
Applic* ant states that the construction permit for Unit 1 should not be suspended, in whole or in~part, pending completion ~ ~~~
of the NEPA environmental review for the reasons which are
, explained below. In preparing this statement, Applicant has attempted to apply to Unit 1 the critcria specified in Para-graph II of Section E of Appendix D. .
- 1. 'The continued construction of Unit 1 during the
, prospective NEPA environmental review period will not give rise to any significant' adverse' impact on the environment.
As a foundation for making this statement, Applicant has mad'e ananalysisofthosethingswhichwik.1berequiredtobedone to complete the construction of Unit J . Although it is anticipated that the NEPA environmental re"iew will be completed much sooner than the completion of construction of Unit 1, it is impossible to know at the present time when the review will be completed,
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. and, therefore, the Applicant has analyzed the construction processes as if the review would extend to the completion of construction to the extent that the review period is shorter than this arbitrary assumption. The minimal effects on the environment described below will be further minimized to the extent that the review period is less.
Exploratory drilling and site preparation, including
.__ __.. cl_ earing and grubbing of the construction site,. for Unit 1 _
was completed prior to the issuance of the construction pennit on December 6, 1968. Actual construction 'of the plant was
- begun shortly after this date and has proceeded continuously
'and hs expeditiously as possible since that time. Construction
, of Unit 1 is now more than sixty-five per cent complete.
All excavation and the building of permanent buildings has already been completed. The remaining construction work consists primarily of the installation of equipment and systems in the buildings. -
Applicant has stated in some detail in its Environmental Report on Unit 1 heretofore filed the manner in which the con-struction process itself would affect the environment (Environ- .
mental Report pages 76-83). . The inpact of construction on the environment has been and will be inconsequential, and to a
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r very large extent, temporary in nature. Most of the con-struction work which would have a permanent impact on the environment, although it was insignificant, was completed prior to the effective date of NEPA. Adverse effects of construction, if any, will be very temporary and extremely minor in degree.
(a) Liquid Discherges. During the continuance of con-
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~struction 'a'nd until the compie5 ion of construction, there will be no discharge of condenser cooling water into Dardanelle Reservoir. No other heated water will be discharged into the reservoir. Therefore, nothing will be done during the NEPA environmental review which will affect the temperature of the water in Dardanelle Reservoir.' At the present time, the only discharge of liquids from the site of construction of Unit 1 into Dardanelle Reservoir are two discharges of treated sanitary sewage. One is from the temporary construction sewer system, and' the other is from the permanent sanitary sewer system for the plant. The temporary construction sanitary sewage system consists of a 2,000 gallon per day,Aer-O-Flo package sewage treatment plant with chlorination. The actual flow from the discharge from this system is substantially less than the -
rated capacity of the system. The treatment of the sewage in
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this system is effective enough that the discharge has no significant effect on the quality of the water of Dardanelle Reservoir. The Arkansas Pollution Control Commission has issued its penmit authorizing this discharge into the. reservoir (En-vironmental Report, Appendix A, page A.3-2). The permanent sanitary sewer system consists of sewer lines, a septic tank, a sand filter for clarification, chlorination equipment and piping for discharge of the. effluent into Dardanelle Reservoir.
This system was designed and installed in accordance with the requirements of the Arkansas State Department of Health and of the Arkansas Pollution Control Commission. The system is adequate to effectively treat sanitary sewage from 130 people. This
. permanent sanitary sewer system has been approved by the Arkansas State Department of Health, and the discharge thereof has been authorized by the Arkansas Pollution Control Commission (Environ-mental Report, Appendix A, pages A.4-2 and A.6-1). Because of the, effectiveness of the treatr.ent of this sewage prior to discharge into Dardanelle Reservoir, the continued use of the permanent sewer system will have extremely minor effect on the water of Dardanelle Reservoir during the continuance of construction.
If the NEPA environmental review continues until the I l
middle of 1972, there will be some additional discharge into .
Dardanelle Reservoir. At that time the construction forces
will begin to start the cleaning of certain systems of the plant by flushing the snall amount of dirt and corrosion products which have accumulated inside these systems. The liquid used in this cleaning process will be either discharged into Dardanelle Reservoir or disposed of in another manner.
The quantities of chemicals, dirt and corrosion products discharged ,into the reservoir in this process will be so small l
.__._ .. ..._ .__as.to be insignificant. _Even.later,.there.will be.some_ . - . ~ . ._
cleaning of system with chemical solutions, but.these solutions will not be discharged into the environment in violation of present discharge effluent quali.ty standards of federal and
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state regulatory agencies.
If the construction permit for Unit 1 were susp-ciacd, and construction work terminated temporarily, the permanent plant personnel for Unit 1 would continue to remain at 'the site and' continue to use the sanitary sewer system at the plant.
Thusi the_ discharge of offluent from the sanitary sewer systems l l
would not be terminated by the suspension of the construction permit. It is submitted that the continuance of construction
.of Unit 1 will .not have any significant adverse affect on the waters of Dardanelle Reservoir.
-(b) Air. There will be no discharge or release of .
radioactive materials into the air during the continuance of construction of Unit 1 and until an operating license is issued.
The only things which will result in changing the natural abnosphere at the construction site during the con-1 tinuance of' construction will be those things resulting from
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the construction process itself. .These include only dust from motor vehicles moving along unpaved roads and the exhaust from motor vehicles and construction equipment. Construction
, of thd plant was advanced to the point where the use of vehicles and of construction equipment has been substantially .
reduced and will continue to decrease as construction progresses.
The portions of the plant requiring the most use of'such vehicles and equipment has been already completed. As Applicant has stated in its Environmental Report, every effort is continuously being made to keep all roadways watered and as free of dust as is practicable. The dust which 'is raised is minimal and settles within a short period of t.*;me and normally within the boundaries of the plant site. The exhaust fumes from motor vehicles and construction equipment is inconsequential and is i l
dissipated within the boundaries of the site. The effect of the dust and the exhaust fumes is temporary.
The effects on the air of the continued construction of Unit 1 are insignificant, temporary and localized within the plant boundaries. They are the necessary results of any construction process. The ?uspension of the cors truction permit would delay these effects on the atmosphere until a later time.
(c) Natural Ecology. Prior to the beginning of work on Unit 1, the actual site on which it is being constructed was covered with grass, weeds, bdshes and scrubby trees. A small part of the construction site was used for pasture, and most of it was not being used for any purpose at all.
This original state of the site has been changed by the construction work. Most of the changes were completely effected prio: 'o January 1, 1970, and all of the changes i 1
which will be effacted by the completion of the plant have already been effected. The trees and bushes on the immediate construction site have been removed, and the grass and weeds on the same site have been destroyed in the process of excava-tan or covered up with construction facilities. Small portions.
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of the terrain have been changed by excavations for the emergency cooling pond and for the intake and discharge
, canals. All of the work which would result in such changes to the ecology has been completed, and the continuance of construction will not cause any further changes.
It is not definitely known whether or not there was any
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small wildlife such as rabbits, squirrels, quail, and other birds on the actual construction site prior to the beginning s:
of construction. There were no larger wild animals inhabiting the site. To the extent that there may have been small wildlife
~ on the construction site, they have already'bcen displaced by~
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the construction w6rk and have moved over into surrounding portions of the land which are still substantially identical to the original state of the construction site. The contin-uance of construction will not re"11t in any further displace-ment of small wildlife, and if the construction were suspended, such wildlife would not return to the construction site in its present condition.
It is Applicant's opinion that the changes which have been made in the original st. ate of the construction site will be beneficial rather than sdverse to the environment as a e ,-- r - - - , - - -
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whole. Those changen have already been made, and the completion of construction without suspension of the construction permit
.w ill not result in any further changes to the terrain, the growth on the site, and any wildlife which may be there.
(d) Disturbance of Reservoir. In the course of constructing Unit 1, it has been necessary to do some excavation and dredging in and adjacent to the embayments of Dardanelle Reservoir at the termina of the intake and discharge canals. In addition, it has been necessary to remove some stumps frcm the bottom of the embayments at the end of the discharge canal in order to permit the entry of barges arid to facilitate the flow from the discharge canal. This excavation, dredging and stump removal has resulted in some m'inor, temporary turbidity in the water of the embayments. The work was done in such a manner as to minimize the turbidity and prevent, to the extent possible, any siltation. All of this work was done with the approval of the Corps of Engineers and in accordan .e with its direction. The work was also done in accordance with the suggestions made by state and federal agencies having juris .
diction over fish life. The turbidity created by this work was temporary and localized and has completely cleared. The f
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only work remaining to be done of this nature is the removal of some existing dikes across the intake and discharge canals which are presently holding the waters of the reservoir out of the plant facilities. It is anticipated that this removal work will be done in January of 1972. That work will result in an insignificant amount of turbidity in the water for a
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few days while the work is going on.
It is submitted that the continuance of construction of Unit 1 will not result in any significant adverse effect on the clarity of the water of Dardanelle Reservoir.
.(e) Aesthetics. The Environmental Report aforefiled by .the Applicant is this proceeding describes the things
'shich Applicant intends to JEd is doing in making Unit 1 and its site as pleasing in appearance as is possible. It is the opinion of Applicant that when the plant is completed and landscaped, it will be' attractive in appearance and aesthetically appealing. The suspension of construction at thi : time could not restore the site to its original appearance.
All of the structures which will appear above ground have been built or installed except a super-structure over an oil storage vault,-two tanks and a small amount of work in the switchyard.
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Substantially, all of the remaining construction work will consist of-installations within existing buildings, and the completion of work which will be largely decorative in nature on the outside of buildings. If the construction work is continued, it will result in the finishing of the work designed to make the plant more attractive, the removal of debris and of construction materials and equipnent and the landscaping of the site. Unquestionably, this finishe'd plant will be more aesthetically appealing than is the present appearance of the construction' site. The suspension of the construction permit woul'd itself have an adverse effect on 'the appearance s
of this plant by delaying the work of makin~g it more attractive.
(f) Historic and Archeological. Applicant has ' stated in its Environmental Report that there is nothing of historic or archeological value at the actual construction site.
Therefore, the construction work could not have any adverse effect on things of this value.
Applicant states that there will be no other effects on the environment resulting from the~ continuing of .
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construction except as have been outlined above. The l impact of the environment from the completion of the construction, if it is adverse at all, will be insignifi- ,
1 cant. The cessation of construction at this time would j I
at best delay the improvement of the appearance of the plant to the extent that there will be an impact on I the environment. It will be temporary in nature and will correct itself by the time of completion of con-struction. If the NEPA environmental review should result in a modification suspension or termination of the construction permit, any impact on the environment, however insignificant, to which the continued construc-
" tion might give rise, will have been redressed by the time such modification, suspension or termination is made
- effective.
2 The continued construction of Unit 1 during the prospective NEPA environmental review period will not fore-close the subsequent adoption of any alternatives in facility design or operation of the type that could result from the review. In making this statement, Applicant has again arbitrarily assumed that the NEPA review might possibly extend to the completion of construction of Unit 1, although this does not seem possible. ._
The design of Unit 1 is now approximately ninety-five -
per cent complete. The work remaining to be done on the design of the plant relates largely to details. Therefore, any m'odifications which might result from the NEPA environmental
. review will necessitate eithe , supplementary design or changes in design already made. This fact is true now and will cortinue to be true until the completion of construction. Such design supplements or revisions could be done as well after the com-pletion of construction as they could be at the present time.
As has been stated above, the construction of Unit 1 is more than sixty-five per cent complete at the preser.t time.
In addition, substantially all of t51e mejor equipment haa either been manufactured or i's in the process of being e
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manufactured. The structural portions of the plant have been completed already. The construction work remaining to be done consists almost entirely of the installation of equipment and systems within existing structures. If modifications in the design or in the m thod of operation of the plant are required as.a result of the NEPA environmental review, the, economics of construction probably will dictate that these modifications be accomplished by additions to the plant as presently designed rather than changes in those portions of the plant as presently designed. This fact is true whether those modifications be made at the present stage
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of construction.of the plant or after the' construction in accordance with the present des,ign is . completed. If any changes (as distinguished from additions to) in the plant as presently designed are required, these chang s can be accompish'ed as quickly and as economically after the installa-tion, of equipment and systems as they could be if th a changes were begun at the present stage of constnaction of the plant.
It is . Applicant's opinion that no modifications in the design of Unit 1 will be required as a result of the remainder ,
of the NEPA Environmental Report. It is convinced that its 4
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.. .. , _ . . . . ., : . .. . .- .. .- .a Environmental Report heretofore filed and the supplement to that Environmental Report, which Applicant is now preparing, ;
will be convincing that any adverse impact on the environment from the operation of Unit 1 as presently designed will not l~ be significant. The exhaustive study of the environmental i
. impact required by the Arkansas Pollution Control Commission before it issued its permit and the modifications in. design resulting from those studies lead the Applicant to believe l that furEher review of the environmental impact will not lead 4
to any additional modification of design. Nonetheless, being j cognizant of the fact that the opinions of this Commission on environmental matters,may differ from those of the Arkansas .
Pollution Coatrol Commission, Applicant has attempted to' analyze those areas in which this commission might possibly determine i
that modificaticns ~in' design are necessary.
"' sed upon the I contingents made by environmentaliste in other situations, it' appears that the most likely areas for close scrutiny by this Commission with respect to Unit 1 are the discharge of ,
condenser cooling water into Dardanelle Reservoir and the discharge or release of radioactive wastes into the environ-ment. Applicant has carefully studied these two areas as to Unit 1.-.
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The present design of Unit 1 proposes that condenser cooling water will be discharged from the plant into an embayment and thence into Dardanelle Reservoir. The plant has been so designed that the rise in temperature of this ,
cooling water is only.15 . Applicant has made extensive mathematical studies and an extensive scale model study of f
the effect which the' discharge of this cooling water will have on Dardanelle Reservoir. As a result of these studies, and its own investigation, the Arkansas Pollution Control Commission, after a public hearing, concluded that the discharge would comply with its water quality standards as to temperature effects and authorized the discharge (Environmental Report, Appendix A, pages A.2-2 and A.2-3). The water quality standards of that Commission had been approved under the provisions of the Federal Water Pollution Control Act. As indicated above, these approvals and acceptances were given only af ter the public hearing conducted by the Arkansas Pollution Control Commission at which the public was invited to appear and present any views which it might have with respect to the impact of the discharge on Dardanelle Reservoir.
Applicant has made studies of possible modifications in the design of Unit 1 which might be made in the unlikely event that the Atomic Energy Commission should be of the opinion that the knpact on Dardanelle Reservoir of the discharge of condenser cooling water is not acceptable.
Any one of these modifications could be made after the completion'of construction of Unit 1 or at any thne hereafter during the construction period as economically and as quickly as such modification could be made at the present stage of construction of Unit 1. The first such possible modifica-tion would be the installation and utilization ci topping towers or a natural draft cooling tower. Such modification would involve the construction and installation of the tower itself, the installation of piping to the tower, and the installation of pumps. Substantially, all of this work would be done outside other structures of the plant as presently des'igned to the extent that such an installation would require work within other structures. Those other structures have already been completed. If cooling towers were installed, economics would probably also dictate modifications in the
condenser. The condenser has, however, already been
, installed, and the modifications could be made as quickly and as inexpensively after completion of construction of Unit 1 as it could at the present stage of construction.
A second alternative in modification would be the installation of a condenser bypass arrangement. This would involve increasing the intake flow of cooling water, bypassing the condenser with a portion of this intake flov , and resultant mixing. of the heated and unheated intake flow in the discharge canal. This modification would' involve only the installation of additional pumps, valves and piping. The modification would be made largely outside struc'tures presently designed to the extent that this modification would involve construction work ,
in or connected with presently designed structures. The construction of those structures has already been completed.
The$efore, this modification could be made as economically and as quickly after the completion of construction of Unit 1 i
as it could be if the mouification .were begun at the present stage of construction of Unit 1. 1
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T third alternative for the reducing of the effect of the condenser cooling water discharge on Lake Dardanelle is the construction of a weir across the embayment into which the discharge canal empties. This construction' work would be accomplished entirely separate and apart from any portion of the plant as , presently designed and could be done as quickly and as econbmically after the completion of construction of
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the plant as it could at the present stage of constru'ction.
Any one of the modifications outlined above would be very expensive at any time. Those governmental agencies which have reviewed the present design of Unit 1 have determined that the impact of condenser cooling water upon Dardanelle , Reservoir ,
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is not substantial enough to justify the expenditure of the money -required for any one of these alternatives. If, however, -
this commission should reach a different conclusion, the continued construction of Unit 1 during the NEPA environmental review would not ' preclude the making of any of these modifications.
The second area in which Applicant recognizes that this Commission might possibly require modifications in design to reduce the impact on the environment is the reductionof the discharge or release of radioactive wastes in gaseous or liquid l .
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- o affluent. Unit L as presently designed and being constructed, will collect, monitor and treat all radioactive wastes so -
that releases to the environment will be as low as practicable and well below the limits established by present regulations of this commission. .I f , as a result of the NEPA environmental-review, this Commission should determine that the releases of radioactive wastes should be further controlled or reduced, the modifications in design could, in the opinion. of Applicant, best and most economically be accomplished by additions to the plant as presently designed rather than actual changes in the present design. These additions could be constructed as quickly, as economically, and as conveniently after the remainder of the plant has bedn completed as they could if the construction were to begin at the present stage of con-struction of Unit 1. To the" extent that these additions would be tied in with presently designed structures, those structures hav'e been already constructed. If this commission should for any reason determine that modification in the presently designed waste control and disposal system,s (as distinguished from additions thereto) were necessary, those modifications could be made after the completion of construction. The construction m
i of these waste systems has progressed to the point' already that the continued installation of the systems would not be a substantial deterrent to any modifications the Commission ;
might direct.
In view of the above, it appears to Applicant that the suspension of the construction permitfor Unit 1 would not in any way,substantially facilitate the making of any modifications
-' in design of Unit 1 which might result from the NEPA environ-mental review. Certainly, the continued constructil'on during the review period would not foreclose the adoption of alterations
, in design which might become necessary.
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. 3. A delay in the construction of Unit 1 such that it is not availsble for commercial operation in 1974 will
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significantly affect the ability of not only the Applicant's 4
system but the entire Middle South Utilities System to meet -
. 4 the public need for power generation. Applicant is one of the five operating companies of the Middle South Utilities.
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'All generation is planned and installed to meet the forecasted l l
load of Middle South as,a whole. Through a contractual arrange- l
. ment, reserves are shared by each 'of 'the five companies.
- The total presently installed generating capability of l
Applicant is 2,366,000 KW consisting of'five steam electric w ,, -
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l plants with a total installed capability of 2,200,000 KW, five gas turbine generating units with a total installed caphbility of 91,000 KW, two hydroelectric plants with a total installed capability of 69,000 KW and diesel electric 3
units with a total capability of 6 MW. In addition, Applicant is a party to a contract with the Southwestern Power Administra-tion which allows Applicant to purchase 161,000 KW per year and to a dlversity interchange with Tennessee Valley Authority
- to exchange 171,000 KW per year. The peak demand on Applicant's '
system in 1971 was 2,535,000 KW, an increase of 11.0% over the maximum experienced in 1970. In recent years Applicant's i
actual load growth has consistently exceeded its projected i
1 I load growth. l i.
Each of the five operatin'g companies of Middle South i
Utilities constructs generating units to meet additional ,
i requirements of the entire Middle South System and sells capacity and energy therefrom to the other companies. This arr'angement enables each company to install larger and more economical generating units than would otherwise be feasible.
l As a result of this planning arrangement, it was determined 1
that Applicant should add a generating unit of 850 MWe to its
. system to be-placed in operation in 1973 in order to me'et the B - _ . , . , - . - , - - , _
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Middle South area's growing power requirements and to take care of contingencies which might arise. Applicant considered all types of fuels for this unit. At the time of this evalua-tion, fossil fuels were not economically competitive with nuclear fuel. In addition to the economic advantages of nucler.r fuel over fossil fuel, Applicant felt that the benefits in the area of environmental air pollution would make a nuclear
.,_.._. fueled unit.a bet.ter. choice.when.the public. interest.is con- . . _ _ . . . _
sidered. As a result, the decision was made to install Unit 1. -
Since the original decision was made, the growing shortage of natural gas has accentuated the necessity for generating capacity not dependent on fossil fuel. While Applicant is
.stil[dedicatedtothegoalofservingthegrowingdemand ,
of its customers for electric power, it has been forced by develognents in 1970 to become deeply concerned about its ability to continue to serve its present load. The increasing l l
seriousness of the gas shortage has made it more important ;
that Unit 1 be placed in commercial operation at as early a
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date as is possible. '
All of Applicant's steam elect.ric generating plants anI 1 its gas turbine generating units were originally designed to use natural gas as their primary- fuel. The steam generating
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units have facilities available whereby they can use oil as a,n alternative fuel during short periods of emergency.
The use of oil as the sole fuel for extended periods of time not only reduces the capacity of the generating units, j but in addition fouls them to the extent that they require
- substantially more down time for maintenance and repa,ir. i Applicarit does not presently have facilities sufficient to 4 . . . - . . . . _ store enough.. oil to. use it-. continuously as --the sole. fuel at . _ - - - . - -
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its generating units.
.During the last year Applicant has suffered increasing curtailments of the supply of gas to its generating units.
'The gas suppliers state that these curta' lments i are necessary
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as a result of shortages of their reserves of gas. On April 1, 1971, the contract for the gas supply to one of the steam electric generating plants of Applicant (144 MW capacity) expired,'and Applicant i. s been unable to obtain a supply of gas.as fuel for this plant. Since that time, this plant has operated with oil as its sole fuel. Its status as a reliable source of continuous production of power has been impaired.
Arkansas-Louisiana Gas ' Company (Arkla), the principal supplier of natural gas for' Applicant's other steam generating
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-units, has been stating that its reserves of gas were short
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.v and that it would be necessary for it to curtail the gas supDly to all of its industrial customers more and more. .
Its curtailments of the supply to Applicant during the summer of 1971 have been very substantially in excess of any curtail-ments ever experienced before by Applicant. Historically, gas curtailments to Applicant have occurred only in cold weather when the pipeline system was unable to carry gas sufficient to meet the demand. Generally,'there were no gas curtailments in the summer. As a result of gas curtailments in July 1971, Applicant was forced to burn $747,000 of fuel . ...
oil in its generating units. .,.
'In early 1971, in response to the claims of the gas shortage, the Arkansas Public Service Commissio'n instituted proceedings to determine ~whether or not any action should be taken with respect to the industrial gas contract of Arkla. Substantially, all of the remaining gas supply contracts of the Applicant were involved in this proceeding. After lengthy hearings, on August 9, 1971, the Public Service Commission issued an Order which, in effect, cancelled all of Arkla's industrial gas contracts, including those with Applicant. This Order was made effective immediately, and while Applicant has appealed the decision to the Court, it cannot predict what the outcome of
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the proceeding will be. Unless and until the Courts reverse the decision of the Public Service Commission, Applicant will'have no firm commitment for the supply of gas for its generating units.
The Order of the Public Service Commission also recognized the fact that Arkla does have a shortage of gas reserves and that it 'wogld be unable to supply the needs of its industrial
- . _.. customers in full. It, therefore,_ set up a schedule of - - - - - -
priorities of curtailments of the gas supplies of these customers, including Applicant. A portion of Applicant's gas supply is in the second category of customers to be curtailed, and a portion of it is in the third category of customers to be curtailed. Those customers in the first category of curtailment have been curtailed 100 per cent since the effective date of the Order. All of the customers in the second category have been curtailed substantially each day since the Order became effective. Arkla has stated that the curtailment of gas supplies to its industrial customers will progressively increase in the foreseeable future.
g In addition to the above proceedings, the Federal Power commission (FPC) on April 15, 1971, issued its O'rder No. 431 directing all gas and pipeline companies to file reports and 4
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tariff provisions containing curtailment. plans, if unusual curtailments were anticipated as a result of gas shortages.
In response to this Order, Arkla on May 18, 1971, filed tariff sheets stating it would be necessary for it to curtail the supply to its industrial customers and setting forth a schedule of priority classifications for such curtailment. ,
Under tile curtailment plan filed by Arkla with the FPC, Arkla ,.
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- -would be permitted to, and has stated .that it wouldrcurtail - ~-
the gas supply to Applicant substantially more than it is
__.. Permitted..to do_.under the curtailment _ priorities.. promulgated .
by the Arkansas Public Service Commission. The FPC has tat yet ruled on the curtailment plan of Arkla in this proceeding. -
It is impossible at the,present time to know with any -
degree of accuracy the extentto which the shortage of gas q supply of Arkla will affect the ability of. App $.icant to continue to generate enough power to fulfill the demands of its customers. The Arkansas Public Service Commission has considered the situation serious enough that it has required the Applicant and other electric utilities operating in Arkansas
[ to file with it for approval, plans for the curtailment of the supply of electric power to the electric customers of Applicant
- and other electric utilities. If the plan filed by Applicant
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is implemented, all of ita customers would be called on to reduce their consumption o'f electricity, and its industrial and large commercial customers would be required to reduce their business activities. Some of these customers could be .
required to shut down completely.
Other companies in the Middle South System are also being affected by the shortage of gas reserves. United Gas Pipeline Company, a primary supplier of gas to Louisiana Power & Light Company and Mississippi Power & Light Company, has also filed with the FPC pursuant to FPC Order No. 431 new tariffs con-
. taining plans for the curtailment of the gas supply to its industrial customers. Both Louisiana Power & Light Company and Mississippi Power & Light Company have already suffered some curtailment of their gas supplies.
If the curtailments of the gas supply to A plicant's generating units continue to increase at the rate predicted by Arkla, it will become essential that Unit 1 be placed in commercial operation as soon as possible. Unit 1 will be the l
only generating unit on Applicant's system which was not designed for the use of fossil. fuel's and which will not be affected by gas curtailments. Any delay in placing this unit l
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in commercial operation will' increase the possibility that j there will be a serious shortage of electric power in Arkansas i
and on the Middle South Utilities System.
- 4. A suspension of the construction permit for Unit 1 and the resultant delay in completion of the plant and its commercial operation would impose substantial additional costs upon Applicant, its investors and its customers, and would have adverse _ economic and planning effects on the local community and the surrounding area. Some of the direct adverse effects of the suspension would be as follows: l
-(a) Bechtel Corporation, the engineer-architect-constructor for Unit 1, has estimate'd that the direct construction costs of l a three-month suspension of the construction permit would- be
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approximately $6,400,000. This would include the costs of demobilization, remobilization, engineering, continuing Bechtel l home office expense, continuing field non-manual labor expense, maintenance and protection of constructed work and equipment, penalties on subcontracts, out of sequence construction problems escalation and contingencies. The comparabl~e cost for a sus-pension of six months has ~been estimated 'tE.be .412,000,000.
. (b)' Up to October 1, 1971, Applicant had invested in the
, plant in cash approximately $102,000,000. Interest during Revision 1 October 22, 1971
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construction on this investment at the conservative rate of 7h per cent during the time of the delay would be approxi- .
mately $21,000 per day. In addition, Applicant has firm commitr unts to purchase machinery and equipment having a purchase price of approximately $21.,110,000. To the extent that this equipment might be delivered during the suspension period, Applicant would be required to pay for it and interest would begin to accrue on this additional investment. Interest
. during construction on Applicant's investment in switchyard
_ - and transmission facilities being constructed to serve Arkansas Nuclear One would be approximately $1800 per day.
. _ (c) Other costs which Applicant would continue to incur during the period of delay in construction caused by any sus-pension of construction would include:
(1) Premiums on insurance on the partially constructed plant would continue at a cost of approximately $5000 per month; (2) The payroll costs of the staff which has been assigned to training for operation of the plant would continue at the rate of approxi-mately $50,000 per month; ,
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(3) The payroll cost of personnel in the home office of the Production Department whose duties relate directly to the construction of Unit 1, would continue at the rate of approximately $12,000 per month; (4) Applicant will have other overhead expenses which will continue during the period of delay in construction, but it _is not practi- __ . . __
cal to attempt to compute the amount of this cost.
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. ("d) To the extent that there is,a delay in the construction of Unit 1, there will.be a del y in the commercial operation of
. this unit. During this period of delay in operations, Applicant will be forced to generate electric power with fossil fuels if it is able to obtain those fossil fuels. Fossi'l fuels are more ~
expensive than nuclear fuel, and, therefore, the cost of power generated will be increased for the duration of the delay.
Table 1, which is, attached hereto, shows what this increased fuel cost would be for periods of delay from three months to twelve months. This increase in fuel cost is based on the energy to be replaced while Unit 1 is not available for commercial operation and takes into consideration the fuel
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cost of nuclear energy and the fuel cost of fossil ~ fuel replacement energy. A portion of this additional fuel cost -
would be an economic penelty on Applicant itself, and a portion of the cost would be passed on to the consumers under existing rate schedules and would be an economic penalty on the'public in the State of Arkansas.
(e), Any delay in the operation of Unit 1 would probably
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have an impact on the training program for plant operators who are to be licensed by the Atomic Energy Commission,.in addition to the continuation of their payroll cost. These plant operators are now involved in a planned training program
--~ Which is designed' ~~to have these nien ready for ~ l'icensing at the"~--~ ~
'a~ppropriate time prior to fuel loading.
If Unit 1 were delayed for a considerable period of 't .me, a re-assessment of the training program muld have to be made so that .these operators .
would not reach the peak of their training at a time inconsistent with their licensing and the schedule of the plant. If the
.per.od of delay should turn out to be an extended one, it might be necessary to add a refresher course to the training program.
(f) A delay in the constiruction of Unit 1 would impose an adverse economic penalty on the local community and the surrounding area.
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(1) Suspension of construction activities would create a period of un-employment for over 600 construction workers and a payrollloss of $132,000 per week to the surrounding community; (2) A suspension of construction -
c activi, ties would also cause a loss of i'ncome to numerous construction support activities in the local community and surrounding cities. The income from this source is estbuated to amount to a monthly
' average of $30,000 for Russellville, $125,000 focLittle Roc'k, $6000 for, Fort Smith, and $7000 farthe rest of the Stater r (3) A delay in the construction and .
op6 ration of Unit 1 would cause a corres-
, ponding delay in the full tax assessment on this facility and would thereby temporarily reduce the expected tax receipts for local governmental bodies. Local governmental bodies which participate in these tax receipt,s include
- Russellville School District No. 14, Pope County ,
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General Fund, Pope County Road Fund,.
, Pope County Industrial Fund, and Pope County Library Fund. Ad valorem taxes are payable to these governmental agencies based on the value of the construction work com-pleted at the end of each year. Taxes paid based on the 1970 assessment were $224,763.
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were $546,440. The g'overnmental agencies -
are aware of the increasing value of this facility, which constitute.a substantial portion of their tax income. They have made and are making plans based upon the continued construction of the facility. Any delay in construction could have an adverse impact on
. s their planning.
. (g) A delay in the construction and operation of Unit 1 would cause a delay in the planning and construction of the site recreation facilities which will be available to.the public. 'These recreational facilities are scheduled to be opened to the public when Unit 1 is completed and in operation.
The facilities are to be coordinated with and become a part of
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other recreational facilities in the vicinity of the plant site. The tourist and recreational industry is a substantial segment of the business in the area near the plant. The local community anticipates that Applicant's site recreational facilities will substantially enhance the tourist and recreational business. A delay in the opening of these facilities will have an adverse impact on the economy of the surrounding area.
(h) As has been pointed out above, a delay in the operation of Unit 1 may cause a shortage of electric power in Arkansas. This could result in the hnplementation of the electric power curtailment plan required by the Arkansas Public Service Commission. Such a curtailment would have a substantial impact on the economy of the State of Arkansas.
Applicant submits that the suspension of the construction permit for Unit 1 could not have the effect of preventing any adverse impact on the environment and would have a serious adverse effect upon Applicant, the community surrounding the plant site, and the State of Arkansas. Therefore, Applicant requests that there be no suspension of the construction permit.
ARKANSAS POWER & LIGHT COMPANY By f Y%r /
Vice Pr'esid'ent/
STATE OF ARKANSAS )
) SS :
E COUNTY OF PULASKI )
W. M. Murphey, being duly sworn, states that he is a Vice President of Arkansas Power & Light Company; that he is authorized on the part of said Company to sign and file.
I with the Atomic Energy Commission this' Statement; that he has read all of the statements contained in such Statement [
and that all such statements made and matters set forth ;
therein are true and correct to the best of his knowledge, information and belief.
/',, A, g" // 4 ~ J,m p b.,'
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W. M'. M6rphey ,-
SUBSCRIBED AND SWORN TO before me, a Notary Public in
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and for the County and State above named, this 15th day of October, 1971.
L' l ,K d. A Notary Public My commission expires:
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,V TABLE 1 .
ADDED FUEL COSTS CAUSED BY DEIAYS IN COMPLETION OF ARKANSAS NUCLEAR ONE - UNIT 1 MKWH OF UUOLEAR FUEL COST OF HUCLEAR* FUEL COST OF REPIAC.** bCREASEDFUELCOSTDUE PERIOD OF DELAY DIERGY ENERGY . - . ENERGY TO COMPIEfION DEIAYS IN COMPLETION TO BE REPLACED $ $ __
Sept. 1 - Nov. 30, '73 1,162,500 $ 1,838,000 $ 3,742,000 $1,904,000 D c. 1 - Dec. 31, '73 387,500 613,000 1,247,000 634,000 Jan. 1 - Feb. 28, '74 1,000,000 1,581,000 3,312,000 '1,731,000 Mar. 1 - May 31, '74 1,500,000 2,371,500 4,968,000 ,
2,596,500 Junn 1 - Sept. 1, '74 1,500,000 2,371,500 4,968,000 2,596,500 TOTAIS 5,550,000 $8,775,000 *
$18,237,000 $ 9,462,000 TOTAL INCREASED FUEL COSTS NO. OF MONTHS TO AP&L AND ITS CON-0F DEIAY SUMERS DUE TO DEIAY OF IN COMPLETION NUCLEAR ENERGY - $
- Based on 1581 Mins /kwh 3 $ 1,904,000 (1973) ** Based on 3 219 Mins in 1973 and 3.312 Mills in 1974 6 4,269,000 (2,538,000 - 1973; 1,731,000 - 1974) -
9 6,865,500
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12 9,462,000 -
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